While defining the extent of contamination at Rocco’s Landfill, also known as the Sutton Brook Disposal Area, information regarding waste at nearby properties surfaced. Beginning on October 24, 1999, The Massachusetts Department of Environmental Protection and the United States Environmental Protection Agency (EPA) began a Preliminary Assessment/Site Investigation (PA/SI) at the Wilmington Disposal Area (WDA) Site located at 1079 South Street, Tewksbury, Massachusetts. The entire property is 117 acres which includes parcels within Tewksbury and Wilmington. The drum disposal area investigated during this PA/SI covered approximately ½ acre within the Wilmington parcels. A second drum disposal area within the Tewksbury parcel was identified to EPA by an informant during the removal action and subsequently investigated. There was a gate on the main access road at 1079 South Street, but for the most part, access was unrestricted. There are no residences in the immediate vicinity of the drum disposal area, but portions of the property are used by hunters, motorcyclists and mountain bikers. The owners of the property operate a piggery, raise horses and ponies for seasonal hay rides and children’s pony rides, and grow flowers in on-site greenhouses, all on the Tewksbury parcels. They also grow pumpkins and ornamental corn for seasonal sale in the field adjacent to the drum area. The first PA/SI resulted in the discovery of contaminated soil along with approximately 50 drums just below the ground surface, adjacent to approximately 100 drums that were protruding from a berm next to a small pond and wetlands. During the second PA/SI, a handful of crushed drums and containers and a small amount of contaminated soil were discovered. The majority of the drums in both locations were in various stages of decay and appear to have been crushed and/or ripped up at the time of disposal. Samples collected from drum contents in one of the test pits indicates high levels of volatile and semi-volatile organics and heavy metals.

A short term cleanup (REMOVAL) at the site was started on 5/8/00 and completed on 7/24/01.

On January 19, 2000, EPA issued a closure memorandum indicating that a removal action was necessary at the Site. A Notice of Responsibility Letter was sent to the property owner, but the response indicated that the owner did not have the resources to finance a removal action. On May 8, the EPA contractor began to mobilize personnel and equipment to the site. Excavation of drums, containers, and contaminated soil began soon after site preparation activities. On August 9, 2000, transportation and disposal activities began. As soil was being analyzed for disposal purposes, polychlorinated biphenyls (PCBs) were detected in some of the samples. Additional samples of previously excavated and stockpiled soil were collected and analyzed, and dependent upon PCB concentrations, the soil was shipped to different disposal facilities. On August 22, 23, and 24, 2000, approximately 718 tons of contaminated soil were transported off-site for treatment (thermal desorption) and disposal at Environmental Soil Management, Inc. (ESMI) in Loudon, New Hampshire. On September 18, 19, and 29, approximately 320 tons of soil were transported off-site for disposal at the Chemical Waste landfill in Model City, New York. This soil was shipped on a hazardous waste manifest due to higher PCB concentrations. Once this soil was removed, additional screening for PCBs in surface soil was conducted. The few locations where PCBs exceeded 10 parts per million were excavated and approximately 169 tons were stockpiled. This soil was transported off-site for disposal at ESMI on December 22, 2000. In addition, 20 cubic yards of crushed empty drums and debris were shipped off-site for landfill disposal and 53 overpacked drums were transported off-site for landfill disposal. On November 22, 2000, an informant, familiar with the site history, pointed out a second location where he believed a number of drums and waste had been disposed of, probably as long as 35 years ago.Beginning on December 6, 2000, EPA’s contractor began laying a protective cover of geotechnical fabric and clean soil over the first drum disposal area that had been previously excavated to prevent incidental contact with residual PCB contamination. On December 18, 2000, EPA began investigative work at the new suspect disposal area. Two test pits indicated drum carcasses, containers, and/or contaminated soil. On May 14 and 15, 2001, the two contaminated areas were excavated and the material was placed into three rolloff containers. These roll-offs were shipped off-site for disposal on July 23 and 24, 2001. Photos